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- ICI Comment Letters
- ICI Files Comment Letter with CFTC on "Project KISS" (pdf)
Sep 28, 2017
- ICI Files Comment Letter on CFTC Recordkeeping Proposal (pdf)
Mar 20, 2017
- ICI Files Comment Letter on CFTC Proposal to Amend Recordkeeping Requirements for DCM and SEF Members (pdf)
Jan 13, 2015
- ICI and Other Trade Associations Submit Amended Letter to CFTC Staff Requesting Relief to Net Uncleared Swaps (pdf)
Sep 3, 2014
- ICI Submits Second Letter Seeking Clarifications on Final Harmonization Rules for Registered Fund Advisers That Are Commodity Pool Operators
Sep 24, 2013
- ICI Submits Follow-Up Letter to CFTC Staff Regarding Certain SEC Exemptive orders and No-Action Letters; NFA Makes Amended Compliance Rule 2-45 Effective
Sep 16, 2013
- ICI Letter to CFTC Staff Seeks Clarification of Final Harmonization Rules for Registered Fund Advisers That Are Commodity Pool Operators (pdf)
Aug 28, 2013
- Supplemental Filing In Lawsuit Challenging Rule 4.5 Amendments (pdf)
Jun 17, 2013
- ICI and IAA Submit Proposed FAQs to the CFTC and NFA on Forms CPO-PQR, CTA-PR, NFA Form PQR, and NFA Form PR (pdf)
Jun 7, 2013
- ICI and SIFMA AMG Request Confirmation from CFTC and NFA Regarding Reporting Obligations of Funds' Wholly-Owned Subsidiaries (pdf)
Apr 10, 2013
- ICI Submits Request to CFTC Staff for Fund of Funds Guidance (pdf)
Feb 26, 2013
- Mutual Fund Directors Forum and Former SEC Commissioners and Senior Officials File Amicus Brief in Support of ICI, Chamber (pdf)
Feb 6, 2013
- ICI, U.S. Chamber Brief Filed in Appeal Challenging CFTC Rule (pdf)
Jan 30, 2013
- Compliance with Registration Requirements Under Amended Regulations 4.5 and 4.13(a)(3) (pdf)
Jan 25, 2013
- Order Granting Expedited Consideration of Appeal in Lawsuit Challenging CFTC Amendments to Rule 4.5
Jan 15, 2013
- ICI, U.S. Chamber File Motion for Expedited Consideration of Appeal in Lawsuit Challenging CFTC Amendments to Rule 4.5 (pdf)
Jan 3, 2013
- NFA Regulations as Applied to Registered Investment Companies and Their Advisers (pdf)
Dec 28, 2012
- Application of NFA Rules to Registered Investment Companies Unable to Rely on CFTC Rule 4.5 and their Advisers (pdf)
Dec 28, 2012
- NFA Compliance Rule 2-45 (pdf)
Dec 21, 2012
- CFTC Regulation 4.20(c) (pdf)
Dec 21, 2012
- Request for Temporary Registration Relief for Commodity Pool Operators and Commodity Trading Advisors that Must Register as a Result of Amended CFTC Regulation 4.5 (pdf)
Dec 20, 2012
- Regulation 4.5 Harmonization (pdf)
Nov 29, 2012
- Focus on Funds: ICI Responds in Rule 4.5 Lawsuit
Jul 6, 2012
- ICI, Chamber File Reply Brief in Lawsuit Challenging Amendments to Rule 4.5 (pdf)
Jul 2, 2012
- ICI Files Comment Letter and Cost-Benefit Analysis on CFTC Rule 4.5 Harmonization Proposal (pdf)
Apr 24, 2012
- History of Rule 4.5 (pdf)
Apr 17, 2012
- Rule 4.5: Mutual Funds and Their Investors Benefit from Commodity Investments and Other Derivatives (pdf)
Apr 17, 2012
- CFTC's Cost-Benefit Analysis on Rule 4.5 Amendments: Insufficient, Incomplete, and "Unlikely [to] Survive Judicial Scrutiny" (pdf)
Apr 17, 2012
- Higher Cost and Fewer Choices: Rule 4.5's Impact on Investors (pdf)
Apr 17, 2012
- CFTC's Rule 4.5 is Government Regulation at Its Worst: A Flawed Process Produces a Flawed Rule that Increases Investors' Costs (pdf)
Apr 17, 2012
- Clouds Overhead: Financial Regulation After the Crisis
Mar 19, 2012
- ICI Comment Letter: Follow-up to July 6, 2011 Roundtable on CFTC Proposal to Amend Rule 4.5 (pdf)
Jul 28, 2011
- ICI Comment Letter on CFTC Proposal to Narrow Rule 4.5 Exclusion for Funds (pdf)
Apr 12, 2011
- ICI and IDC Comment Letters on CFTC Proposal to Narrow Rule 4.5 Exclusion for Funds
Apr 12, 2011
- ICI Letter On NFA Petition To Narrow CFTC Rule 4.5 Exclusion For REGISTERED Investment Companies (pdf)
Oct 18, 2010
- ICI COMMENT LETTER ON PROPOSED AMENDMENTS TO CFTC RULE 4.5 (pdf)
Apr 29, 2003

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